Last Updated/Effective Date: January 1, 2020
Note to Established Clients
How We Collect and Use Your Personal Information
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.
The categories of Personal Information we collect from you depend on your interactions with us. For example, we may collect:
- Identifiers and contact information, such as your name, email address, mailing address, phone numbers, IP addresses, and unique identifiers such as your usernames and passwords. We collect this information directly from you and from third-party sources for the purpose of creating and managing your DTSC account (“Account”), for communicating with you, verifying your identity, and providing our Services to you.
- Transactional information, such as credit or debit card numbers. We collect this information directly from you in order to process your payments for our Services.
- Commercial information, such as products and services you have purchased from us. We collect this information to maintain registered member records, identify trends in our registered member relationships, and conduct business analytics.
- Profile information and inferences, such as information about your preferences and characteristics. We collect profile information by drawing inferences from the above categories of Personal Information in order to understand your preferences and tailor our services and communications to you.
In addition to the purposes for collection described above, we also collect your Personal Information for the following general purposes:
- To maintain and service your Account, including to fulfill your orders, to confirm your orders, to send you requested product and Service information, and to send you product and Service updates;
- To respond to your customer service requests and address your questions and concerns;
- To send you newsletters and marketing communications;
- To administer and improve our Services and marketing efforts, including measuring the effectiveness of the websites, diagnosing problems with our servers, and analyzing traffic;
- To detect security incidents, to protect against malicious, deceptive, fraudulent or illegal activity, and to comply with our policies and procedures;
- To comply with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.
How We Share and Disclose Your Personal Information
We may share your Personal Information in the following circumstances:
- Publicly, but only with your permission: We may share your Personal Information publicly with your permission. For example, with your permission, we may publicly post your photograph, your name, professional titles, and comments on the “Reviews” section of our websites.
- To Service Providers: We may share your Personal Information with companies that provide services to us, such as for hosting, marketing and communication services, and payment processing (“Service Providers”). Our policy is to authorize these Service Providers to use your Personal Information only as necessary to provide services for us, and require that they not use or disclose your Personal Information for any other purpose.
- From time to time, we may be required to provide Personal Information to a third party in order to comply with a subpoena, court order, government investigation, or similar legal process.
- We may also share your Personal Information to third parties, such as law enforcement agencies, when we, in good faith, believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- We will also share your Personal Information to any other third party with your prior consent to do so.
- In a corporate transaction: If DTSC is involved in a bankruptcy, merger, acquisition, reorganization, or sale of all or a portion of its assets, we may share or transfer your Personal Information as part of any such transaction.
We do not sell your Personal Information
Access and Choice
If your Personal Information changes, or if you no longer desire our Services, you may modify or remove it by logging into your Account and making the changes in your Account settings.
Marketing Opt-out Preferences
You can opt out of receiving marketing emails by using the unsubscribe link contained in the email. We may still send you emails about your relationship with us and your transactions, including Account information and alerts, purchase confirmations, and updates to our products, services and policies.
Tracking Technologies and Cookies
We use information gathered from these tracking technologies so that we can analyze trends, administer the Services, track users’ movements around the Services, and gather demographic information about our user base as a whole. We may combine information we obtain through tracking technologies with other Personal Information that we have collected about you in order to make our Services, communications and advertisements more targeted to your interests.
Most web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. If you reject cookies, you may still use our Services, but your ability to use some areas of our Services will be limited. You may also opt out of targeted advertisements by visiting the Network Advertising Initiative opt out page.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (https://adssettings.google.com/authenticated).
Do Not Track
Please note that the Services are not presently configured to respond to DNT or “do not track” signals from web browsers or mobile devices. As such, we do not recognize or respond to Do Not Track requests.
Retention and Security
We will retain your Personal Information for as long as your Account is active, as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information (such as your login credentials), we encrypt the transmission of that information using secure socket layer technology (SSL). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
California Privacy Rights
California residents have certain rights under the California Shine the Light law and the California Consumer Privacy Act (“CCPA”).
In general, within the preceding 12 months:
- We have collected the categories of Personal Information listed in the How We Collect and Use Your Personal Information section above.
- We have collected these categories of Personal Information directly from you, when you use our Services, and from third parties for the purposes described in the How We Collect and Use Your Personal Information section above.
- We have disclosed the following categories of Personal Information for business purposes: Identifiers and contact information; professional and employment-related information; commercial information; transactional information; and internet and network activity information.
- We have not sold your Personal Information.
CCPA Privacy Rights
Certain California residents are entitled to privacy rights under the CCPA. Customers who wish to exercise these rights should direct their requests to the registered member who controls their Personal Information.
- The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information.
- The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
- The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services.
You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, please contact us using the address information provided at the bottom of this document.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
Shine the Light
California customers are also entitled to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information please contact us in writing using the address information provided at the bottom of this document.
Our Services are not directed to, and we do not knowingly collect any Personal Information from children under 13.
Information for Visitors from Outside of the United States
Links to Other Sites
Changes to This Policy
Attn: Privacy Officer
1598 Pearl Street, Suite 2
Eugene, Oregon 97401